Privacy Policy

Twundle (“we,” “us,” “our”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, share, and protect your information when you use our website, apps, early-access list, and related services (“Services”).

By using Twundle, you agree to the practices described in this Privacy Policy.

1. Information We Collect

We collect information in the following categories:

1.1 Information You Provide

• First name, email address, and password (stored only as a one-way hash)
• Date of birth, gender identity, and who you would like to meet
• Photos, captions, and profile content
• Your location, as a postal code or your device’s location rounded to about 100 meters
• Messages, likes, and other interactions with members
• Reports and blocks you make
• Phone number, if you verify one
• Payment information (processed by third-party providers; we do not see your full card number)
• Messages you send us through our contact form and, only if you allow us to reply, the email address to reply to. You can send a message anonymously, signed in or not

If you join our early-access list, we collect your email address, an optional ZIP code, and the campaign link that brought you to us, if any. If you join through a friend’s invite link, we record whose link it was, so they get credit under our Founding Offer Terms. They see only how many people have joined with their link, never who.

We do not require or request:

• Social Security numbers
• Government IDs
• Financial account numbers

1.2 Automatically Collected Information

We collect:

• Device information (model, operating system, browser)
• IP address
• App usage data, such as when you were last active
• Log files and diagnostic data
• Cookies and similar technologies, as described in our Cookie Policy

We do not collect your precise location without your explicit permission, and when you share it, we round it before storing it.

1.3 Sensitive Information

Some information you share may be sensitive, such as:

• Gender identity
• Sexual orientation, as implied by who you would like to meet
• Details you choose to include in your profile

We treat this data with heightened protection and never share it with advertisers or data brokers.

1.4 Your Photos and Your Face

We do not use facial recognition. No software at Twundle measures or maps your face, and we never sell your photos or give them to facial-recognition companies.

When photo verification is offered, it will be your choice: you take a selfie copying a pose shown on screen, and a person on our team compares it by eye with your profile photos. The selfie is deleted as soon as that decision is made; we keep only whether your photos were verified, and when.

1.5 Information from Third Parties

We may receive:

• Payment confirmations
• App store purchase data
• Verification results (for example, that a phone number received our code)

We do not purchase user data from third-party sources.

2. How We Use Your Information

We use your information to:

2.1 Operate the Service

• Create and manage your account
• Display your profile to other members
• Show you people nearby and facilitate matches and communication
• Provide customer support
• Grant the Founding Offer and invite rewards to those who qualify

2.2 Improve the Service

• Analyze usage patterns in aggregate
• Develop new features
• Decide where to launch, using early-access ZIP codes in aggregate

2.3 Safety & Integrity

• Detect fraud, spam, and harmful behavior
• Limit how often actions can be taken, to stop abuse
• Enforce our Terms of Service
• Comply with legal obligations

2.4 Communication

• Send sign-in and verification codes
• Notify you of new matches or messages
• Provide account and security alerts
• Tell early-access members when Twundle opens near them

We do not send marketing emails without consent, and every marketing email includes a way to unsubscribe.

3. How We Share Your Information

We share your information only in the following situations:

3.1 With Other Members

Your profile, photos, and shared content are visible to other Twundle members according to your settings.

We never show other members your exact location, last name, or contact information. Members see an approximate distance, not where you are.

3.2 With Service Providers

We use trusted third-party providers for:

• Cloud hosting and content delivery
• Database hosting
• Email delivery
• Text message delivery
• Payment processing
• Security and fraud detection

When you choose a password, we check whether it has appeared in a known data breach. Only the first five characters of a one-way hash of the password leave our systems, so the checking service never learns your password.

These providers are contractually prohibited from:

• Selling your data
• Using your data for advertising
• Using your data for any purpose other than providing services to Twundle

3.3 Legal Requirements

We may disclose information if required by:

• Law
• Court order
• Government request
• The need to prevent harm or illegal activity

Our Law Enforcement Request Policy explains how we handle these requests.

3.4 With Your Consent

We may share information for optional features, but only with your explicit permission.

3.5 Not With Other Apps

Twundle is an independent app, not part of a group of dating apps. We do not share your information with any other app or company for its own use, including any other app run by our founder.

4. What We Never Do

To avoid the issues that led to FTC actions against other dating apps, Twundle will never:

• Sell your personal data
• Sell your photos or profile information
• Give your photos to facial-recognition companies, or use facial recognition ourselves
• Share your data with other apps, including affiliated ones
• Share your data with advertisers
• Show other members your precise location
• Misrepresent how your data is used
• Share your data with third parties for “research” without consent
• Use dark patterns to force data sharing

5. Automated Decision-Making

Twundle uses automated systems to:

• Order the profiles shown to you
• Detect spam, scams, and harmful behavior
• Screen photos before other members see them

Photo screening asks an AI model, run on our hosting provider’s servers, whether a photo shows content our Community Guidelines forbid, such as nudity, violence, or contact details: phone numbers, social media handles, web addresses, or QR codes. It describes what is in a photo; it does not recognize or measure faces. A photo it is unsure about waits for a person on our team to decide. The model is not trained on your photos, and the provider does not use them for any purpose of its own.

These systems may analyze:

• Profile content and photos
• Interaction patterns, such as how often actions are taken

What automated systems do not do:

• Make the final decision to remove an account without human review
• Read private messages for advertising
• Sell or share your data externally

You may object to automated processing where the law gives you that right.

6. Cookies & Tracking Technologies

We use only the cookies needed to:

• Keep you signed in
• Keep your session secure
• Protect the Services from automated abuse

We measure visits to our website without cookies, and we do not use third-party advertising cookies or tracking pixels. See our Cookie Policy.

7. Data Retention

We retain your data only as long as necessary to:

• Provide the Services
• Comply with legal obligations
• Resolve disputes

Some data is removed on a fixed schedule:

• Photos rejected in review are deleted within 7 days
• Photo-verification selfies are deleted as soon as a decision is made
• Messages sent through our contact form are deleted 180 days after we close them, unless they are part of an open report or the law requires us to keep them
• Records used to limit how often actions are taken are deleted within days
• Early-access list entries are deleted when you unsubscribe or create an account. When you create an account, we keep with it only what the Founding Offer needs: that you qualified, and the invite rewards you earned

Upon account deletion:

• Your profile is removed immediately
• Messages may remain for safety and fraud prevention
• If you received the Founding Offer, we keep a record of it so we can answer any question about whether it was honored: which way you qualified, your place in the count, the dates, and the version of the offer terms. It holds your email address only as a one-way hash, which can confirm a match but cannot be read back, and none of your profile, photos or messages
• Backups are purged on a scheduled cycle

You may request full data deletion at any time. Your Data & Account Deletion explains how.

8. Data Security

We use industry-standard security measures including:

• Encryption in transit and at rest
• Passwords stored only as one-way hashes
• Access controls
• Monitoring for unusual sign-in activity

No system is 100% secure, but we take all reasonable steps to protect your data.

9. International Data Transfers

If you access Twundle outside the United States, your data may be transferred to and processed in the U.S.

We use:

• Standard Contractual Clauses
• Adequacy safeguards
• Additional security measures

10. Your Rights

Depending on your location, you may have rights to:

• Access your data
• Correct inaccurate data
• Delete your data
• Restrict processing
• Object to automated processing
• Request a copy of your data
• Withdraw consent

We honor all applicable privacy laws (GDPR, CCPA, etc.).

11. Children’s Privacy

Twundle is for adults 18+.

We do not knowingly collect data from minors.

12. Changes to This Policy

We may update this Privacy Policy periodically.

We will notify you of material changes through the Services or by email.

Continued use of the Services constitutes acceptance of the updated policy.

13. Contact Us

Twundle

privacy@twundle.com